1 particularly influential medium in Myanmar. More than 14 million people out [of] a total 2 population of 53 million utilize Facebook in Myanmar, and according to a 2016 survey of 3 internet users in Myanmar, ‘reading news on the internet’ often meant ‘news they had seen on 4 their Facebook newsfeed, and [they] did not seem aware of other news sources online.’”72 5 87. The New York Times has reported that “[t]he military exploited Facebook’s wide 6 reach in Myanmar, where it is so broadly used that many of the country’s 18 million internet 7 users confuse the Silicon Valley social media platform with the internet,”73 and that “[a]s 8 Facebook’s presence in Myanmar grew …, the company did not address what the BSR report 9 calls ‘a crisis of digital literacy’ in a country that was just emerging from a military dictatorship 10 and where the internet was still new.”74 11 12 88. In the end, the U.N. put it best: “Facebook has been a useful instrument for those seeking to spread hate, in a context where, for most users, Facebook is the Internet.”75 13 III. 14 15 Facebook Amplified the Myanmar Military’s Use of Fear and Hatred of the Rohingya to Justify its Hold on Power 89. By 2011, the country’s history of political repression and ethnic violence was 16 widely known. “Myanmar’s political history has been heavily dominated by an all-powerful 17 military, known as the Myanmar ‘Tatmadaw,’ which has ruled the country for most of its 18 19 20 21 22 23 24 25 26 27 28 72 Fortify Rights, They Gave Them Long Swords: Preparations for Genocide and Crimes Against Humanity Against Rohingya Muslims in Rakhine State, Myanmar at 95, n.403 (July 2018), https://www.fortifyrights.org/downloads/Fortify_Rights_Long_Swords_July_2018.pdf (“Fortify Rights Report”) (citing GSMA, Mobile Phones, Internet, and Gender in Myanmar at 55 (Feb. 2016), https://www.gsma.com/mobilefordevelopment/wpcontent/uploads/2016/02/Mobile-phones-internet-and-gender-in-Myanmar.pdf.) 73 Paul Mozur, A Genocide Incited on Facebook, With Posts From Myanmar’s Military, NEW YORK TIMES (Oct. 15, 2018), https://www.nytimes.com/2018/10/15/technology/myanmarfacebook-genocide.html. 74 Alexandra Stevenson, Facebook Admits It Was Used to Incite Violence in Myanmar, NEW YORK TIMES (Nov. 6, 2018), https://www.nytimes.com/2018/11/06/technology/myanmarfacebook.html. 75 Report of the detailed findings of the Independent International Fact-Finding Mission on Myanmar, UNITED NATIONS HUMAN RIGHTS COUNCIL (Sept. 17, 2018), https://documents-ddsny.un.org/doc/UNDOC/GEN/G18/274/54/PDF/G1827454.pdf?OpenElement (“UNHRC Report”) ¶ 74. CLASS ACTION COMPLAINT 32 Case No. __________________